Monday, June 29, 2015

Consti II case digest:RIZAL ALIH, et al. petitioners, vs. MAJOR GENERAL DELFIN C. CASTRO, et al. respondents

Right Against Self-Incrimination
Scope and Coverage

G.R. No. L-69401 June 23, 1987


FACTS:
On November 25, 1984, a contingent of more than two hundred soldier implemented a “zona” and raided the compound occupied Rizal Alih and the other petitioners at Gov. Alvarez street, Zamboanga City, in search of loose firearms, ammunition and other explosives. 

The people inside the compound resisted the invasion which resulted to a shoot-out resulting to a number of casualties. The besieged compound surrendered the following morning, and sixteen male occupants were arrested, later to be finger-printed, paraffin-tested and photographed over their objection. The military also inventoried and confiscated nine M16 rifles, one M14 rifle, nine rifle grenades, and several rounds of ammunition found in the premises. 

On December 21, 1984, the petitioners came to this Court in a petition for prohibition and mandamus with preliminary injunction and restraining order. Their purpose was to recover the articles seized from them, to prevent these from being used as evidence against them, and to challenge their finger-printing, photographing and paraffin-testing as violative of their right against self-incrimination. 

ISSUE:
Whether or not the finger-printing, paraffin-testing and taking of photographs of the seized occupants are violations of the constitutional guarantee against the self-incrimination.

RULING:


No. The photographing, fingerprinting and paraffin-testing of the petitioners are not violations against the right against self-incrimination. The prohibition against self-incrimination applies to testimonial compulsion only. The prohibition of compelling a man in a criminal court to be a witness against himself is a prohibition of the use of physical or moral compulsion to extort communications from him, not an exclusion of his body as evidence when it may be material.

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